Indonesian opposition/tax court | Deadlines, fines, and practical responses

Indonesia

#Tax audit/transfer pricing

What is opposition/tax court in Indonesia? Explanation of deadlines, payment obligations, and fines

Latest update date: July 16, 2026 Posted date: December 27, 2021

Indonesian Tax Tribunal is a procedure in which taxpayers dispute the results of tax audits or appeals in the tax court.

As a result of a tax audit in Indonesia, you may not only be denied a refund, but also be subject to a large amount of additional tax, even though you were in a position to receive a refund when you filed your tax return.

However, just because a tax correction decision notice is issued as a result of a tax audit does not mean that the tax office's decision has been finalized.

If you are not satisfied with the results of the tax audit, you can file an "objection" with the National Tax Agency. Additionally, if you are dissatisfied with the appeal decision, you can appeal to the Tax Court.

In fact, there are cases in which taxpayer claims that were not accepted at the tax audit or opposition stage are accepted in tax court.

On the other hand, oppositions and tax trials each have strict filing deadlines and formal requirements. Additionally, if the taxpayer's claim is not accepted as a result, a penalty may be imposed in addition to the additional tax amount.

This article explains the procedures, deadlines, payment obligations, and fines for oppositions and tax courts in Indonesia based on the system as of July 2026.

What you can learn from this article

Procedures if you are dissatisfied with the tax audit results
Deadline for filing an opposition and main application requirements
Amount that must be paid before filing an opposition
Tax court procedures and trial period
Fines if you lose in opposition or tax court
Important practical points in tax disputes

1．． Indonesian tax court and opposition process

If a tax correction decision notice (SKP) is issued as a result of a tax audit and you are not satisfied with its contents, you can first file an objection with the Directorate General of Taxation.

Furthermore, if you are dissatisfied with the decision on the appeal, you can appeal to the Tax Court.

The general procedure flow is as follows.

Issuance of tax correction decision notice (SKP)
↓
Objection (Keberatan)
↓
Issuance of opposition decision
↓
Appeal to Tax Court (Banding)
↓
Tax Court Judgment

Appeals and tax trials each have their own filing deadlines and formal requirements.

If you miss the deadline or do not meet the necessary formal requirements, you may not be able to proceed to review your claim.

Therefore, it is important to promptly consider your response policy upon receiving the SKP or the appeal decision.

2．． Objection

2-1．． What is an appeal?

An appeal (Keberatan) is a procedure in which a taxpayer requests the Directorate General of Taxation for reexamination of an SKP issued by the tax office.

The main objects of the objection are as follows.

kinds	content
SKPKB	Tax deficiency determination notification
SKPKBT	Additional tax deficiency determination notification
SKPLB	Tax overpayment amount determination notification
SKPN	Zero tax determination notification
Withholding/tax collection	Withholding or collection of taxes by third parties

In filing an appeal, it is not enough to simply claim that you are not satisfied with the tax office's decision.

The taxpayer must organize and submit the tax amount that the taxpayer believes to be correct, the basis for its calculation, the reason for not agreeing to the tax office's correction, related laws and regulations, and evidence.

2-2．． Deadline for filing opposition

As a general rule, an appeal must be filed within three months from the date the SKP was shipped to the taxpayer.

As a general rule, the starting point for the deadline is the date the SKP is shipped, not the date the SKP is confirmed internally or the date it is reported to the Japanese head office.

Therefore, when you receive an SKP, you should check not only the date stated on the notification letter, but also the date of shipment and receipt record.

An exception may be granted if it can be proven that the taxpayer was unable to submit by the deadline due to circumstances not attributable to the taxpayer. However, in practice, preparations should be made on the assumption that the application will be submitted within three months.

2-3．． Main requirements for opposition

In order for an appeal to be effective, the following requirements must generally be met:

Creating documents in Indonesian
11 SKP or 1 withholding/tax collection per 1 objection form
Enter the tax amount that the taxpayer believes is correct.
Clearly state the reasons why you disagree with the tax office's decision
Submit within the legal deadline
Must be signed by the taxpayer or an authorized representative
The taxpayer has paid the amount agreed upon at the final consultation of the tax audit.

Even if the content of your claim is valid, if it does not meet formal requirements such as submission deadline and signature authority, it may not be heard as an opposition.

Therefore, it is necessary to carefully check not only the content but also the format of the application documents.

2-4．． Amount to be paid before filing an opposition

When filing a protest, it is not necessary to pay the full amount of additional tax listed on the SKP.

However, the amount agreed upon by the taxpayer himself at the PAHP, which is the final consultation of the tax audit, must be paid before filing the objection form.

On the other hand, if the taxpayer does not agree with the PAHP, there is no need to pay it at the stage of filing an appeal.

For example, even if the amount of additional tax stated in the SKP is Rp10 billion, but the amount agreed to by the taxpayer in the PAHP is Rp1 billion, in principle, the amount that needs to be paid before filing an objection is Rp1 billion.

The remaining Rp9 billion can be filed for opposition.

Therefore, which points you agree with and which points you dispute in PAHP will directly affect your subsequent payment obligations.

Rather than simply agreeing to the tax office's findings in order to end the negotiations quickly, it is necessary to make a decision with an eye toward filing an objection or tax court.

2-5．． Examination of appeals

Once the objection form is received, the Directorate General of Taxation will conduct an examination based on the following materials:

Objection form
Materials related to tax audits
Contracts and documents submitted by the taxpayer
Accounting books and tax returns
Grounds for correction by tax office
Explanations submitted by both the taxpayer and the tax office

During the examination process, the Directorate General of Taxation may request additional documents or explanations.

In addition, before a decision is issued, taxpayers are usually issued a Notice of Attendance (SPUH: Surat Pemberitahuan Untuk Hadir) to receive an explanation of the content of the examination and an opportunity to express their opinions.

After confirming the opinion of the Directorate General of Taxation, the taxpayer submits a written rebuttal or additional explanation.

2-6．． Handling of materials not submitted for tax audits

In the case of an appeal, there is a possibility that books, records, materials, etc. that were requested to be submitted at the tax audit stage but were not submitted without a valid reason will not be considered in the examination.

Therefore, at the time of a tax audit, it is important to organize and submit the necessary evidence in anticipation of future objections and tax trials, rather than just responding to the tax office's questions on an ad hoc basis.

In particular, the following materials may be important in tax disputes:

contract
invoice
Bank remittance record
Accounting books
Board of Directors minutes
business report
email
work record
transfer pricing documentation
Internal documents explaining the actual status of transactions

Merely having a contract may not be enough to prove the reality of the transaction.

It is necessary to prepare materials that explain that the services and assets were actually used in accordance with the terms of the contract and that the local subsidiary received profits as a result.

2-7．． Deadline for decision on appeal

In principle, the DGT must issue a decision within 12 months of receiving the opposition notice.

12If a decision is not issued within a month, in principle, the taxpayer's appeal will be treated as approved.

The main outcomes of an appeal include:

All allowed
Partially allowed
rejection
Increase in tax amount

As a result of filing an appeal, there is a possibility that the amount of tax paid will be higher than the original SKP.

An appeal is not just a procedure to have the contents of the SKP reconfirmed. Since this is a procedure in which the National Tax Agency reexamines the entire case, it is necessary to consider the risk of the tax amount being increased.

2-8．． Fines if the objection is not accepted

If the opposition is rejected or only partially approved, a 30% fine will be imposed as a general rule.

Fines are calculated based on the following amounts:

Tax amount based on the appeal decision - Tax amount paid before the appeal decision

For example, if the amount of additional tax collected after the appeal decision is Rp10 billion and you have paid Rp2 billion before filing the appeal, as a general rule, a 30% penalty will be calculated on the difference of Rp8 billion.

The fine in this case is Rp2.4 billion.

However, if the appeal decision is appealed to the Tax Court, the 30% appeal penalty will not be imposed at that time.

Ultimately, the application of penalties on appeal will be determined based on the Tax Court's ruling.

3．． tax court

3-1．． What is a tax trial?

Indonesian tax courts examine whether the judgments of the tax office or the Directorate General of Taxation are appropriate in light of laws and facts.

If you are not satisfied with the decision of the appeal, you can file an appeal (banding) with the Tax Court.

The Tax Court is a separate judicial body from the DGT and hears arguments and evidence submitted by both taxpayers and the DGT.

Even if a taxpayer's claim is not accepted at the tax audit or opposition stage, there are cases where the claim is accepted in a tax court.

In the tax court, whether the tax office's correction is appropriate in light of the law and the facts is examined again.

Therefore, if you receive a large amount of additional tax, it is important to maintain consistency in your claims and evidence from the tax audit stage to the tax trial.

3-2．． Tax court filing deadline

As a general rule, an appeal to the Tax Court must be filed within three months from the date of receipt of the appeal decision.

In the case of an opposition, the starting point for the deadline is the date on which the SKP is sent, whereas in tax courts, the starting point is, in principle, the date on which the opposition decision is received.

As a general rule, appeals will not be accepted after the deadline.

After receiving the written opposition decision, there is a limited period of time to consider whether to file an appeal and to prepare a letter of appeal, summary of issues, evidence, etc.

Therefore, it is advisable to prepare for the possibility that the case will go to tax court even while the appeal is being examined.

3-3．． Is it necessary to pay when appealing to a tax court?

In the past, the general explanation was that 50% of the disputed tax amount had to be paid in advance in order to file a tax tribunal.

However, with regard to general national taxes under the jurisdiction of the National Taxation Bureau, under the current Act on General Rules for National Taxes, the deadline for payment of amounts that the taxpayer has not agreed to in the final consultation of the tax audit is, in principle, postponed until a judgment is issued by the Tax Court.

Therefore, for general national tax appeals, it is not appropriate to uniformly explain that 50% of the appeal decision amount must be paid at the time the appeal is filed.

However, applicable laws and procedures may differ regarding local taxes, customs duties/excise taxes, land and building taxes, etc.

When actually filing a tax lawsuit, it is necessary to check the subject tax items, the type of disposition, the amount already paid, etc., and then determine the payment requirements on an individual basis.

3-4．． Main flow of tax trial

Tax trials typically involve multiple hearings.

The general flow is as follows.

Filing an appeal to the Tax Court
Confirmation of formal requirements by the Tax Court
Submission of written answer from the National Tax Agency
Submission of written counterargument from the taxpayer
Confirmation of issues and facts in court
Submission and explanation of evidence
Submission of final opinion
Judgment by the Tax Court

During the actual hearing, the judge asks the taxpayer or the National Tax Agency questions about the details of the transaction, accounting treatment, tax treatment, evidence, etc.

The taxpayer must explain, for each issue at issue, which part of the tax office's correction contradicts the law or the facts.

3-5．． Evidence important in tax trials

In a tax court, it is not enough to simply argue that the tax office's decision is unreasonable.

Objective evidence is required to support the taxpayer's claim.

For example, evidence of transactions is particularly important in the following tax issues:

royalty

Contents of intellectual property used
Actual usage situation
contract
Basis for calculating rates
Economic benefits received by local subsidiaries
Comparison with third party transactions

Management fee/service fee

Contents of the service actually provided
work report
email
meeting records
Person in charge working hours
Benefits received by local subsidiaries
Calculation basis for cost allocation

transfer pricing

transfer pricing documentation
Functions, assets, and risks of transaction parties
Transfer pricing calculation method
Comparable companies or comparable transactions
Reasons for the profit margin and price difference
Transaction terms and business environment

Deducting expenses

Business relevance of expenditure
invoice
contract
payment record
Records of receipt of services or goods
Relationship with company sales acquisition and business activities

In tax litigation, it is important not only to confirm the formal existence of contracts and invoices, but also to be able to explain that the transaction actually took place.

3-6．． Tax court hearing period

In general, the Tax Court is supposed to make a decision on ordinary appeal cases within 12 months after receiving the letter of appeal.

However, if there are special circumstances, the trial period may be extended.

In addition, the actual trial period will vary depending on the following circumstances:

number of issues
Complexity of the case
amount of evidence submitted
Response status from the National Tax Agency
Status of hearing dates
Submission status of additional materials

Since multiple court dates are held in tax courts, it is necessary to prepare an in-house system and financial plan based on the premise that it will take a reasonable amount of time from appeal to judgment.

3-7．． Fines if you lose in tax court

If the appeal to the Tax Court is dismissed or only partially granted, a 60% penalty will be imposed as a general rule.

Fines are calculated based on the following amounts:

Tax amount based on Tax Court judgment - Tax amount paid before filing of objection

For example, if the final amount of additional tax due as determined by the Tax Court is Rp10 billion and you have paid Rp2 billion before filing an objection, in principle a 60% penalty will be calculated on the difference of Rp8 billion.

The fine in this case will be Rp4.8 billion.

Before the tax reform, if the taxpayer's claim was not accepted in the tax court, the penalty was 100%, but it has now been reduced to 60%.

However, the burden is still heavy, so when deciding whether to proceed to tax court, it is necessary to consider the following points:

disputed tax amount
possibility of winning the case
Sufficiency of evidence
Fines if you lose the case
expert fee
Internal response burden
Impact on next year and beyond

3-8．． If you win in tax court

If the taxpayer's claim is accepted in a tax court and it is determined that the amount of tax already paid was excessive, the overpaid amount of tax will, in principle, be refunded.

For example, if you have paid a certain amount before filing an objection, but the additional tax is canceled by a tax court ruling, the amount already paid will be eligible for a refund.

Additionally, if you meet certain requirements, you may be able to receive interest compensation for overpayments.

However, the actual refund amount and interest compensation calculation will vary depending on:

The amount agreed upon in the final discussion of the tax audit
Payment amount before filing an objection
Contents of the Tax Court Judgment
Tax amount eligible for refund
Applicable tax year and legislation

4．． It is important to respond with an eye toward tax litigation.

In order to obtain a good result in an appeal or tax court, it may be too late to consider measures only after the SKP has been issued.

Throughout tax audits, appeals, and tax trials, it is important that the taxpayer's explanation and evidence be consistent.

4-1．． Organize evidence from the tax audit stage

If you fail to submit materials required for a tax audit without reasonable grounds, the materials may not be considered in a subsequent appeal.

Therefore, from the tax audit stage, it is necessary to sort out the following matters for each point pointed out by the tax office.

Tax office's claim
Taxpayer's claim
Related laws and regulations
facts
Evidence
Additional tax amount
Possible counterargument
Policy for handling objections and tax court proceedings

4-2．． Clarifying the scope of consent in PAHP

The amount agreed upon by the taxpayer during the final consultation of the tax audit must be paid before filing an appeal.

Therefore, PAHP needs to clarify which points it agrees with and which points it does not agree with.

You must also ensure that the content is correctly recorded in PAHP minutes, etc.

4-3．． Do not change the description midway through

Changes in explanations at each stage of a tax audit, appeal, or tax trial can reduce the credibility of a taxpayer's claim.

It is important to keep the basic facts and arguments consistent unless new evidence or facts come to light.

It is necessary to check whether there are any contradictions in the tax audit response, opposition letter, and tax court appeal letter.

4-4．． Consider the possibility of success for each issue at issue

1Even if an SKP contains multiple points, it is not necessary to dispute all points in the same way.

For example, it is possible to divide the response policy by issue as follows.

point of contention	Response policy
The tax office's judgment is clearly wrong according to the law.	fight aggressively
there is enough evidence	Considering opposition/tax court proceedings
The facts are correct, but there is a lack of evidence	Consider the possibility of securing additional evidence
There is a clear error in the taxpayer's processing.	Consider agreeing early
The tax amount is small and the corresponding costs are large.	Consider cost-effectiveness

It is important to evaluate the probability of success, tax amount, and risk of fines for each issue, rather than whether you will win or lose the case as a whole.

4-5．． Consider the impact on future years

If the amount of tax in dispute is small, it may be more reasonable not to file an opposition or go to tax court, taking into account expert fees and in-house burdens.

On the other hand, if the same transactions or tax treatment continue in subsequent years, judgments should not be made solely based on the amount of additional tax for that year.

For example, if you accept the tax office's findings regarding transactions that continue from year to year, such as royalties, management fees, transfer prices, and depreciation of fixed assets, you may receive similar findings in future years.

Therefore, it is necessary to make a comprehensive judgment including the following items.

Additional tax amount for the target year
Impact on previous years
Impact on next year and beyond
Impact on other group companies
Potential changes in tax treatment
Review of contracts and transaction methods
Future tax audit risk

5．． Main deadlines and penalties for oppositions and tax trials

The following is a summary of the main deadlines and penalties for oppositions and tax trials.

project	Objection	tax court
procedure	Appeal to the Directorate General of Taxation	Appeal to Tax Court
submission deadline	As a general rule, within 3 months from the SKP shipping date	In principle, within 3 months from the date of receipt of the opposition decision.
propose first	National Tax Agency	tax court
Advance payment	Amount agreed in PAHP	In general national taxes, a uniform 50% advance payment is not required for the disputed portion.
Decision and Judgment Period	In principle, within 12 months	In principle, within 12 months
Fines if the taxpayer's claim is not accepted	Principle 30%	Principle 60%

Submission deadlines are very important.

In particular, care must be taken not to confuse the three months of filing an opposition with the date of dispatch of the SKP, and the three months of tax court with the date of receipt of the opposition decision.

6．． FAQ

Q1. Is it not possible to file an objection unless the additional tax amount listed in the SKP is paid in full?

There is no need to pay the full amount.

However, as a general rule, the amount agreed upon by the taxpayer at the final consultation of the tax audit must be paid before filing an objection.

Parts that the taxpayer does not agree with can be the subject of an appeal.

Q2. Will my tax amount increase if I file a protest?

there is.

Since the Directorate General of Taxation will re-examine the case that has been the subject of an appeal, there is a possibility that the tax amount will be increased from the original SKP due to the appeal decision.

Q3. Can I file a tax lawsuit directly without filing an opposition?

Normally, when disputing the contents of an SKP, you first file an objection, and then appeal the objection decision to the Tax Court.

As a general rule, it is not possible to directly appeal an SKP without filing an opposition.

However, depending on the type of disposition being contested, it may be subject to a tax court action (Gugatan) rather than an opposition.

Q4． Can I submit materials that have not been submitted in the tax audit in the appeal?

Although it is possible to submit documents, there is a possibility that materials that are requested to be submitted in a tax audit but are not submitted without a valid reason may not be considered in the examination of the appeal.

Therefore, it is important to organize evidence from the tax audit stage and submit it at the appropriate time.

Q5. Is there a chance of winning if I go to tax court?

There are cases in which claims that were not accepted in tax audits or oppositions are accepted in tax court.

However, the results will vary depending on the relevant laws, facts, evidence, responses during the tax audit, consistency of the taxpayer's claims, etc.

In addition to the tax amount, it is necessary to consider the sufficiency of evidence and the 60% penalty in the event of a loss.

Q6. If I lose in tax court, will I always be subject to a 60% penalty?

As a general rule, if the appeal is dismissed or partially accepted, a penalty of 60% will be imposed on the remaining amount after deducting the amount paid before filing the appeal from the tax amount based on the tax court's judgment.

However, the actual calculation will vary depending on the amount paid, the content of the judgment, and the circumstances of the case, so it must be confirmed on a case-by-case basis.

7．． summary

Even if you receive a large amount of additional tax due to an Indonesian tax audit, it does not mean that you have to accept the tax office's decision as is.

If you are dissatisfied with the contents of the SKP, you can, in principle, file an objection within three months from the date of shipment of the SKP.

Furthermore, if you are dissatisfied with the decision on the appeal, you can, in principle, appeal to the Tax Court within three months from the date of receipt of the appeal decision.

However, if the taxpayer's claim is not accepted, a fine of 30% in principle in an opposition case and 60% in principle in a tax court may be imposed.

In addition, in oppositions and tax trials, it is important not only the filing deadline and the format of the application, but also what kind of explanation and evidence was submitted at the tax audit stage.

Therefore, if you receive a large amount of tax complaints, it is important to develop a response plan from the time you receive the tax audit result notification (SPHP) to the filing of an objection and tax court, rather than starting to respond after the SKP is issued.

Related laws and regulations

National Tax General Rules Act
Law Number 6 Year 1983 tentang Ketentuan Umum dan Tata Cara Perpajakan (including subsequent amendments)
Tax Reconciliation Act
Law Number 7 Year 2021 Concerning Harmonization of Tax Regulations
Government Order No. 50 of 2022
Government Regulation Number 50 Year 2022 concerning Procedures for Exercising Rights and Fulfilling Tax Obligations
Finance Minister Rules No. 118 of 2024
Minister of Finance Regulation Number 118 Year 2024 regarding Correction Procedures, Object, Reduction, Elimination, and Cancellation in the Field of Taxation
tax court law
Law Number 14 Year 2002 regarding the Tax Court

*This article explains the general system as of July 2026. Actual procedures and payment requirements may vary depending on the tax item, type of disposition, target year, and individual case circumstances.

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